The workshop followed the Implementation Dialogue on biocides hosted by Commissioner Várhelyi in July 2025 and formed part of the targeted consultation for the evaluation. Where the earlier dialogue outlined difficulties in general terms, the reality check examined technical aspects of implementation at a more granular level, around five questions on day-to-day challenges. Participants named guidance documents (frequent updates, inconsistent interpretation across Member States, availability mainly in English), difficulties in finding evaluating competent authorities, especially for Union authorisations, the high cost of data generation and of obtaining access to data owned by other companies, and the unpredictable time needed to obtain approvals.

On the exclusion and substitution criteria, participants acknowledged their rationale but said that the shrinking portfolio of active substances in some uses leaves companies no alternative to substances meeting those criteria. They also raised concerns that products authorised under derogations may be used only by professional users, which limits the substances available for the general public, and said that delays, high regulatory costs, uncertainty and factors outside the Regulation, such as CLP classification and labelling, direct innovation towards non-EU markets. Areas seen as unclear included treated articles, the definition of “data” for data sharing, the handling of delayed authorisation cases and terms such as “trained professional user”, and some participants asked for better articulation between the Biocidal Products Regulation, REACH and CLP under the “One Substance, One Assessment” principle.

Participants also stressed pre- and post-submission meetings with evaluating authorities as good practice and suggested parallel rather than successive discussions in the working groups of the Biocidal Products Committee. For emerging needs, they highlighted sustainability, strategic autonomy and emerging pathogens, and suggested a fast-track procedure for emergencies and shorter timelines for changes to authorisations. The participants included manufacturers such as Arxada, Kemira, Lanxess and Nouryon and associations such as CEPE, Detergents Europe, Biocides for Europe and SME United, with the European Chemicals Agency attending as an observer.

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